Advance
Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty
in relation to the tax impact of their cross-border activities through an
agreement with a tax administration in advance of such activities. APAs can be
unilateral, bilateral, or multilateral depending on the number of national tax
administrations involved, the latter two promising that the agreement made
shall not be questioned in the other affected tax jurisdiction. Departing from
the enhanced mutual agreement procedure (MAP) framework recently established
among Member States through the Tax Dispute Resolution Directive, a future EU
legislative initiative could outline a robust framework for MAP APAs in the Single
Market.